PMCB EPR: where does the reform planned for 2027 stand?

In February 2026, the government announced less expensive construction EPR, with new approvals due to start on 1 January 2027, yet Ecomaison raised some fees by up to 72% this summer. As at 28 September 2026, neither the reform decree nor the ministerial order has been published. The Conseil d’État approved the distinction between "mature" and "non-mature" materials, but recalled that producers must bear at least 80% of costs; according to the ministry’s figures, the targeted saving for 2028 is almost divided by 2.

Until this legislation appears, the framework set in 2022 applies, and the approvals of the 4 producer responsibility organisations run until 31 December 2027. Manufacturers, importers and own-brand retailers must still join, declare products placed on the market and display their unique identifier: the reform will mainly change the amount of the bill and the organisation of waste take-back.

1Who pays PMCB EPR, and for which products?

The extended producer responsibility (EPR) scheme for building construction products and materials, known as PMCB, originated in the 2020 anti-waste law. It has operated since January 2023, and the first EPR fees date from May 2023, according to ADEME.

The products and companies concerned

It covers products permanently incorporated into a building or its plot, in 2 categories: predominantly mineral products (concrete, aggregates, stone, terracotta, ceramics and asphalt mixes) and all others (wood, metal, plaster, plastics, mineral wool, bituminous membranes, joinery and paints). Excavated soil and products used only during construction are excluded.

The EPR fee is paid by the party placing the product on the French market: the manufacturer selling under its own name, the importer or the reseller selling under its own brand. As at 27 September 2026, ADEME counted 10,860 unique identifiers in the scheme; these producers join Ecominéro (mineral products), Ecomaison or Valdelia (other products), or Valobat (the 2 categories).

Why the government is reforming the scheme

In return, the law provided for free take-back of sorted waste and coverage of illegal dumping. The scheme has opened more than 6,000 take-back points, but its cost could reach nearly €920 million in 2028, according to the ministry. Manufacturers consider the charge too heavy, tradespeople the service insufficient, and in March 2025 the government announced a moratorium on several requirements and the launch of the reform.

2The draft reform places 93% of waste among mature materials

The scenario selected on 19 February 2026 was translated in April into draft decrees and ministerial orders, submitted to public consultation until 19 May (1,469 contributions). The 2 texts were due to enter into force on 1 September 2026 and open new approvals on 1 January 2027.

Mature and non-mature materials

Mature materials, whose recycling works without EPR support, are minerals (concrete, tiles, bricks and rubble), metal, wood and, from 2027, plaster: the April draft allowed facilities to charge for their take-back, with the producer responsibility organisation paying only €2 per tonne for sorting and traceability. Non-mature materials (mineral wool, plastics, flat glass and bituminous membranes) continued to be taken back free of charge.

Against the draft ministerial order’s 2025 reference waste volume, the split is highly uneven: 19.7 million tonnes out of 21.2 are mature, or 93% by mass. EPR would concentrate its support on around 1.5 million tonnes, without abandoning its eco-design and reuse targets. Overseas territories remain outside this distinction.

A network entrusted to the regions

The draft entrusts regional councils with mapping take-back points for professionals, department by department, prioritising private commercial waste centres, then voluntary distributors, and finally public waste centres. The take-back requirement for building materials merchants exceeding 4,000 m² would only apply to distributors included in this network, and producer responsibility organisations would stop funding waste removal from construction sites.

The texts also exclude products reserved for public works and require producer responsibility organisations to announce any fee schedule change 9 months before it applies. The illegal dumping fund announced in February, however, requires legislative provisions, according to the ministry.

3The Conseil d’État recalls that producers pay at least 80% of costs

The draft decree was sent to the Conseil d’État in June 2026. According to the minister’s reply published in the Senate’s Journal officiel on 10 September, the high court approves the reform’s overall structure and the distinction between mature and non-mature materials, without challenging the end of on-site take-back above 50 m³ or the end of distributors’ general obligation.

However, it recalls Article 8a of the Waste Framework Directive: a state can depart from full cost coverage only if producers bear at least 80%. With the Conseil d’État’s changes, the 2028 budget would fall only to around €600 million, according to the ministry, including nearly 10% for the future illegal dumping fund, compared with €325 million in the initial draft. Against the €920 million expected without reform, the saving falls from €595 to €320 million.

Minister Delegate Mathieu Lefèvre submitted the opinion to stakeholders in a letter dated 7 September, according to the local authorities’ association AMORCE and Filière Béton; according to Déchets Infos (16 September), he asks them to choose between the text rewritten by the Conseil d’État and the status quo. AMORCE mentions entry into force still envisaged for 1 January 2027, but no publication date has been announced.

CAPEB, which represents building tradespeople, reads in the opinion that calling free take-back into question does not comply with the anti-waste law, and regrets the coordinating body’s strengthened role in the network; Filière Béton calls for inert waste to leave the scheme; the Fédération française du bâtiment opposes the new version, according to Batiactu (17 September).

4How much is the PMCB EPR fee in 2026?

Each producer responsibility organisation publishes its fee schedule, per tonne, cubic metre or unit, and the amount is included in the selling price. The differences are considerable: at Ecominéro on 1 August 2026, a tonne costs €0.40 excl. VAT for aggregates, €1.35 for bricks and €10.26 for cement; at Valdelia in 2026, from €20 for metal products to €280 for paints and mortars.

Increases already under way for non-mature materials

Without waiting for the reform, Ecomaison differentiated its fees on 1 July 2026: +30 to +72% for mineral wool, plastics, glass and bituminous membranes, and no change for metal, wood and plaster sold as single-material products. The reform’s logic therefore already appears in its fees, through an increase restricted to non-mature materials.

The exemption for public works products

Public works companies pay the EPR fee on the concrete, aggregates or precast products they buy, although their structures fall outside the scheme. The Environmental Code requires producer responsibility organisations to offer a deduction for products used in civil engineering, subject to evidence. According to the Fédération nationale des travaux publics (FNTP), it works only in direct sales; the federation is challenging the arrangement before the Conseil d’État and estimates the sums wrongly paid in 2024 at €34 million.

5What should you do while the legislation remains unpublished?

The current requirements remain due, and none of the 4 producer responsibility organisations displayed a 2027 fee schedule on its website on 27 September, but some preparation does not depend on the scenario selected.

• Check your membership and declarations: each product family is declared using the right fee schedule code, and the unique identifier appears in the general terms and conditions of sale and on the website.
• Classify your products as mature or non-mature, to quantify the 2027 bill under the 2 scenarios being discussed.
• Document eco-modulation bonuses (recycled content, certified wood and recyclability); an FDES serves as evidence for some products, such as glazing.
• Maintain waste take-back at building materials merchants exceeding 4,000 m² until the decree is published, and collect declarations of use from public works customers.

For us at Projet Celsius, the costliest mistake would be to build the 2027 budget on the reduction announced in February, when the expected saving has almost been divided by 2. Manufacturers also preparing for the RE2020 2028 carbon threshold benefit from tackling the 2 projects together: the same product data support bonuses, the FDES read by engineering consultancies and calculation of new buildings’ carbon footprint.

6Key takeaways

• No reform legislation has been published as at 28 September 2026: the 2022 framework and current approvals until the end of 2027 apply.
• The draft classifies 93% of waste as mature materials (inert materials, metal, wood and plaster), supported only for sorting and traceability.
• The Conseil d’État approves this principle and recalls the 80% rule: the ministry anticipates around €600 million in 2028 instead of €325 million.
• The 2026 fee schedules are already rising for some non-mature materials, by up to +72% at Ecomaison.
• Membership, declarations and a unique identifier remain required; public works products qualify for a deduction.

Publication of the legislation, or selection of the status quo, will determine whether new approvals start on 1 January 2027 or when the current approvals expire. Other environmental requirements may still change with the 2027 presidential election; for packaging, EPR for professional packaging starts on 1 January 2027. Our guide to building LCA under RE2020 shows how these materials contribute to a structure’s footprint.

Further resources

Frequently asked questions

1Does the PMCB EPR reform enter into force on 1 January 2027?

Nothing guarantees this as at 28 September 2026: neither the decree nor the ministerial order has been published in the Journal officiel, although they were due to enter into force on 1 September 2026 to allow new approvals on 1 January 2027. The government is consulting stakeholders on the version rewritten by the Conseil d’État; according to the local authorities’ association AMORCE, the minister’s letter of 7 September still envisages entry into force on 1 January 2027. Until then, the 2022 specifications apply, and current approvals run until 31 December 2027.

2Which materials are considered mature under PMCB EPR?

In the draft submitted to consultation in April 2026, all predominantly mineral products (concrete, terracotta, stone, aggregates and asphalt mixes), predominantly metal or wood products, and plaster from 1 January 2027 are mature. Mineral wool, plastics, flat glass, bituminous membranes and glazed joinery remain non-mature. The list appears in the ministerial order, which is not yet published.

3Is there an exemption from the PMCB EPR fee?

Yes, for products used in civil engineering and public works: Article R. 543-290-2 of the Environmental Code requires the producer responsibility organisation to offer a deduction subject to evidence, in practice a declaration of use from the customer. Products intended for use outside France also fall outside the scheme. Eco-modulation also reduces the fee for products incorporating recycled materials or certified wood, an opportunity to explore within an eco-design process.

4Who pays the PMCB EPR fee?

The party placing the product on the market: the manufacturer selling in France under its own name, the importer or the distributor selling under its own brand. The amount is included in the price and passed on to the end customer, whether a tradesperson, construction company or private individual. The membership contract may provide for it to be passed on without a discount in the general terms and conditions of sale. A manufacturer established outside France must appoint an authorised representative established in France, as for packaging.

5Must materials distributors still take back construction waste?

Yes, while the reform remains unpublished: the take-back requirement in Article L. 541-10-8 of the Environmental Code applies, under its Article R. 541-160, to distributors whose sales area for construction products and materials exceeds 4,000 m², including adjoining storage. The draft decree restricted this requirement to distributors included in the network defined by the regions, a point the Conseil d’État did not challenge.

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